Israel (Nabble) wrote
Everything is within the US laws.
Unfortunately that doesn't cut it! As you see from the first sentence of Summary on that Wikipedia page:
The GDPR extends the scope of EU data protection law to all foreign companies processing data of EU residents.
If you accept EU-resident users then you are subject to that law. Check out how all the big US players, Facebook, Twitter, eBay, Paypal and the like are bombarding us with emails explaining how they are updating their updating their terms and conditions and adjusting their systems to cope with the new legislation
These emails typically explain what they hold, why they hold it, for how long they might keep it, and how it is now easier for us EU residents to understand terms and conditions, control privacy settings and access the personal data held about us, not to mention about our rights to correct data that may be incorrect and our right as "Data Subjects" to demand to be provided with a full list of all data held on us.
However, I understand that Nabble holds no personal data on EU citizens. I say that on the basis that I believe all Nabble holds is an email address, and that by itself does not constitute personal data. To become personal it has to be linked to other data item such as a name, a real world name, not a user name, or a snail mail address, or telephone number, in such a way that the email address can be linked to a person.
That situation will, of course, change should Nabble ever begin to charge for "advert-free" or other services, as then real world names, addresses, phone numbers, credit card details and other personal data will most definitely be held by you (the "Data Controller", as the law would term you) or some external company (the "Data Processor") that you hire in order to handle payment for the service your user buys. The Data Controller is responsible for how the Data Processor handles its customer's data, so you can't avoid responsibilities by claiming "It was them, not us"!
So I do not believe that Ferdesign need have a concern that you are breaking the law at this point. Nonetheless I would suggest that you should investigate the matter with your lawyers, especially if you are considering charging for added benefits.
We don't sell personal information of our users to other companies.
My understanding was that Nabble simply provides a platform for advertisers and it is they that pay you for displaying ads on your platform and that you provide no personal data to them to assist them to target their adverts or for any other reason. If this is not the case, then you could be in breach of the legislation.
Volunteer Helper - but recommending that users move off the platform!
Once the admin for GregHelp now deleted.
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